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OPENDOEK Privacy Policy

OPENDOEK vzw (hereinafter OPENDOEK) attaches great importance to the protection of your personal data and your right to privacy. In this Privacy Policy we want to provide clear and transparent information about how we handle personal data of contact persons. By contact persons we mean individuals (members, non‑members, former members, teachers, volunteers, suppliers, supporters and others) with whom OPENDOEK comes into contact in the normal day‑to‑day management of the non‑profit organisation.

People who come into contact with OPENDOEK only through our website www.opendoek.be are not included in the central files. For this, see the Privacy Policy www.opendoek.be further on this document. We do everything we can to safeguard your privacy and handle personal data with care. OPENDOEK complies with applicable laws and regulations, including the General Data Protection Regulation (GDPR).

Data Controller – Processor

OPENDOEK is the “data controller” for the personal data entrusted to us directly by the individuals concerned, e.g. directly affiliated persons, teachers, borrowers of the Theaterbib, … (non‑exhaustive list).

OPENDOEK is the “processor” for the personal data entrusted to us by means of “groupings”, e.g. a theatre group, a dance club, a temporary association, a club of theatre enthusiasts, … (non‑exhaustive list), regardless of their legal form or artistic ambition, who affiliate their members with the non‑profit organisation. These “groupings” collect and manage the personal data of the persons affiliated with them in the first instance and must therefore, as organisations, take the necessary steps to bring their own processing procedures into compliance with the GDPR (General Data Protection Regulation).

The fact that the personal data collected and managed by the “grouping” are stored in a computer system made available by OPENDOEK does not transfer this responsibility to OPENDOEK. The lawful acquisition of personal data remains, without exception, the responsibility of the “grouping”.

Responsibility of OPENDOEK

Notwithstanding the above, OPENDOEK manages both the data entrusted to us directly and the data obtained via the “groupings” with the same care and according to the same guidelines.

Our staff members, teachers and volunteers who collaborate with OPENDOEK are aware of our policy, have confirmed in writing that they are aware of it, and are therefore required to work according to the same guidelines.

What does this mean?

  • Your personal data are processed in accordance with the purpose for which they were provided; these purposes and types of personal data are described in this Privacy Policy.
  • The processing of your personal data is limited to only those data that are minimally necessary for the purposes for which they are processed, namely the administrative operation of and the provision of information to members of the non‑profit organisation.
  • Should further processing be required (beyond legal obligations), we will ask for your explicit consent. The processing of sensitive personal data (only when Belgian legislation requires this) is carried out solely by the director. These sensitive personal data are immediately deleted/destroyed after verification.
  • We have taken appropriate technical and organisational measures to ensure the security of your data.
  • We do not pass on personal data to other parties unless this is necessary for the execution of the purposes for which they were provided or when we are legally obliged to do so.
  • We are aware of your rights regarding your personal data and we will respect them.

As OPENDOEK, we are responsible for the processing of your personal data. If, after reading our Privacy Policy, you have any questions about this, you can always contact us through the following channels:

  • By post: OPENDOEK vzw | Italiëlei 6, 2000 Antwerp
  • By email: info@opendoek.be
  • By telephone: +32 3 222 40 90

For what purposes do we process your data?

Your personal data are processed by OPENDOEK for the following purposes and legal grounds:

  • Management of the non‑profit organisation, keeping membership lists of affiliated persons, whether affiliated in a personal capacity or via a “grouping”.
  • Insurance of the affiliated members, which requires OPENDOEK to be able to identify the insured person individually and uniquely.
  • Activities for which OPENDOEK must be able to identify the participating person individually and uniquely:
    • Management of the Theaterbib with regard to borrowed works.
    • Management of the Training Activities with regard to participants.
    • Organisation of festivals, competitions, study days, committees, advisory councils, steering groups, board of directors, general assembly, … (non‑exhaustive list).
    • Legal obligations such as keeping a volunteer register or issuing a tax certificate where required.
  • Sending newsletters and invitations
  • Cooperation with the government:
    • Obtaining subsidies
    • Reporting to the government. This does not take place per individual but rather by age groups and the geographical distribution of the members of the non‑profit organisation, for which certain personal data are necessary (such as date of birth and gender).
  • Financial and accounting processing. For suppliers, volunteers and other persons who in one way or another take part in a financial transaction, we may also store and process bank details (IBAN account number and BIC code). For example:
    • Payment of expense claims, travel expenses, invoices, volunteer allowances, small compensation scheme, fee notes, … (non‑exhaustive list).
    • Collection and reimbursement of membership fees.
    • Collection and reimbursement of participation fees for training activities, festivals, competitions, study days, … (non‑exhaustive list)

For the above purposes, we may request, store, collect and process the following personal data from you:

Salutation, name, first name, address, e‑mail address, language, date of birth, gender, telephone, fax and/or mobile number, website, internal membership number, affiliation with one or more “groupings” within the context of the theatrical arts.

Only where further financial interaction takes place with the person may additional data be required, such as company, place of birth, national register number, VAT number, identity card number, internal supplier number, status, preferred method of reimbursement, IBAN account number and BIC code.

In application of the Decree of the Flemish Government of 3 June 2022 concerning the obligation to check an extract from the criminal record as referred to in Article 596, second paragraph, of the Code of Criminal Procedure for certain new employees, OPENDOEK processes these sensitive personal data where applicable (as defined by the Data Protection Authority at https://www.gegevensbeschermingautoriteit.be).

OPENDOEK provides a member portal to affiliated members via https://mijn.opendoek.be where each affiliated member can consult, modify and delete his/her data (meaning that the above‑mentioned individual data can be deleted; for complete removal from the central files OPENDOEK must be contacted).

Provision to third parties

The data you provide to us may be passed on to third parties if this is necessary for the execution of the purposes described above. For example, we use a third party for:

  • The distribution of newsletters and invitations.
  • The sending of magazines and membership cards (only to persons who do not have an e‑mail address).
  • The social‑secretariat processing of payments to teachers and staff members.
  • The maintenance of the online environment (including development and web hosting).
  • The maintenance of the member portal (including development and server hosting).
  • The maintenance of the IT infrastructure (including the IT network).

We never pass on personal data to other parties with whom we do not have a processor agreement. With these parties, we make the necessary arrangements to ensure the security of your personal data.

Furthermore, we will not pass on your personal data to third parties unless this is legally required and permitted (e.g. police in the context of an investigation).

We may also share personal data with third parties if you give us permission to do so. You have the right to withdraw this consent at any time without affecting the lawfulness of the processing prior to its withdrawal.

OPENDOEK uses Mailchimp as a marketing automation platform. You can consult Mailchimp’s Privacy Policy here: https://mailchimp.com/legal/privacy/

Before 25 May 2018, OPENDOEK offered the entire mailing list the opportunity to give unambiguous consent for continued inclusion in that list. You have the right to withdraw this consent at any time without affecting the lawfulness of the processing prior to its withdrawal.

OPENDOEK does not provide personal data to parties located outside the EU without your explicit consent.

Minors

We only process personal data of minors (people under 16 years of age) if consent has been given by the parent or legal representative.

Please note that – as described earlier – the “grouping” is, where applicable, responsible for obtaining this consent if the member is affiliated with OPENDOEK through a grouping.

Retention period

OPENDOEK does not retain personal data longer than necessary for the purpose for which it was provided.

In the theatre sector, it is not uncommon for individuals to stop their practice and then resume it after several years. For this reason, it is advisable that OPENDOEK retains personal data for a period of 15 years after last use.

In an annual processing, all persons for whom no valid membership has been registered since 30 August of the current year minus 15 will be processed through the procedure Removal from central files.

The e‑mail address may still appear in the Mailchimp mailing list as long as the person does not unsubscribe. This option is offered with every e‑mail sent via the mailing list.

The person naturally has the right at any time to have the personal data deleted; see “Your rights regarding your data”.

Security of the data

We have taken appropriate technical and organisational measures to protect personal data against unlawful processing.

  • All persons who, on behalf of OPENDOEK, may have access to your data are bound to confidentiality.
  • We apply a username and password policy to all our systems.
  • We (or third parties) make back‑ups of personal data to restore them in case of physical or technical incidents.
  • Our staff (own employees or contracted workers) are informed about the importance of protecting personal data.
  • We regularly evaluate our measures.

Your rights regarding your data

You have the right to access and the right to correct or delete the personal data that we have received from you. In this Privacy Policy you will find how you can contact us.

Access: after a simple e‑mail request, OPENDOEK will send the applicant, via the same and registered e‑mail address, within the shortest possible time, a message displaying the stored data. It is possible that this message must be supplemented with manual information (e.g. participation in courses, festivals, loans from the Theatre Library, …). A manually prepared response may entail a longer response time.

Removal from the central files means that OPENDOEK will fully anonymise the personal data so that they can no longer be linked to a person or individual, while still allowing compliance with the statistical obligations imposed by the government. This applies insofar as legally permitted; for example, OPENDOEK must issue a tax form in certain cases. It is therefore not legally permitted to have your data deleted in such a way that no tax form can be issued.

You may also object to the processing of your personal data (or part of it) by us or by one of our employees.

You also have the right to have the data you have provided transferred by us to yourself or, at your request, directly to another party.

To prevent misuse, we may, for each request, ask you to identify yourself adequately. To verify your identity, we ask you to include a copy of your identity card. We strongly recommend making the photograph invisible and indicating that it concerns a copy.

Complaints

If you have a complaint about the processing of your personal data, we ask you to contact us directly.

You always have the right to lodge a complaint with the Data Protection Authority, which in Belgium is the supervisory authority in the field of privacy protection.

Changes to the privacy policy

OPENDOEK may amend its Privacy Policy. We will announce any such change on our website www.opendoek.be

This is the second version of the OPENDOEK Privacy Policy. Older versions of the Privacy Policy have been stored in our archive. Send us an e‑mail if you wish to consult them.

Privacy Policy www.opendoek.be

OPENDOEK attaches great importance to the privacy of internet users. We limit the storage of data to the minimum necessary. And of course, data is never used for any purpose other than the one for which it was provided.

During your regular visit to the website www.opendoek.be and all sub‑sites such as, for example, landjuweel.opendoek.be, spotsopwest.opendoek.be… no personal data is ever requested or recorded. Because we aim to continuously improve opendoek.be, we do measure the number of visitors per page and sometimes also individual traces of visitors across the entire site. However, these traces are never linked to individual data of visitors.

When you submit (personal) data to opendoek.be via a web form, we use this data solely for the purpose for which you provided it. It will never be made available to third parties.

When you send an e‑mail to OPENDOEK via the website, for whatever reason, this e‑mail address is never used for any purpose other than the one for which you have explicitly given permission. We are accustomed to replying to every e‑mail.

Cookies

Within opendoek.be, so‑called “cookies” are used on a limited scale. These are of course not misused to collect personal data.
“Cookies” are small files sent by the OPENDOEK server and placed on the hard drive of your computer. The information stored in these cookies can only be read by us and only during the duration of the visit to the website. Our website uses cookies to distinguish your user preferences from those of other users of our website. This helps us provide you with a better user experience when you visit our website and also allows us to optimise our website. These are, however, not linked to personal data.

It is possible within opendoek.be to store your own settings, links and selections. These too are linked to your own computer by means of a so‑called “cookie”. These links are likewise not connected to personal data.

OPENDOEK uses the following cookies:

  • Technically necessary cookies. These cookies are required to enable the technical functioning of our website.
  • Functional cookies. These cookies are used to provide functionality needed to use our website, such as the ability to store preference settings on a website and other functionalities, whether or not within the duration of the relevant session.

OPENDOEK does not use any additional analytical cookies or marketing‑oriented cookies.

On our website you will find buttons linking to our Facebook, LinkedIn, Instagram and YouTube pages. We do not use tracking via a so‑called pixel.

If you have any questions or remarks about this, please do not hesitate to contact us using the contact details provided in this document.

OPENDOEK privacy procedures

Removal from central files

When being removed from the central files, the surname, first name, address, salutation, email address, login details, language, national register number, telephone, fax and/or mobile number, website, company, place of birth, VAT number, identity card number, status, preferred compensation, IBAN and BIC code, and historical data are deleted from the current version of the central database for membership administration.

If an e‑mail address exists, a final e‑mail will be sent at that moment to the person, confirming the removal together with a unique internal identification number. This e‑mail is not retained by OPENDOEK. The person requesting removal is therefore the only one in possession of the last version of the personal data. The person can reactivate the membership in the future by presenting this unique internal identification number and the personal data from the e‑mail.

Accounting data is retained in accordance with the applicable legislation, which at the time of drafting this policy is set at “during the 10 years (or the 10 financial years) following the taxable period to which they relate.”

Distribution of newsletters

During the annual affiliation with OPENDOEK, in which an e‑mail address is stored in the central membership administration database, either provided by the person themselves or by the membership administrator of the “grouping” through which the person affiliates, the person will be invited, in the e‑mail containing the electronic membership card, to set their newsletter preferences and/or adjust these preferences via https://mijn.opendoek.be.

All members automatically receive the general OPENDOEK newsletter. It is possible to opt in selectively to receive additional e‑mail information on specific topics (such as, for example, the Theatre Library). This is a personal choice that the individual must make themselves via the member portal.

Note that administrative e‑mail communication does not fall under this. For example, OPENDOEK is required to inform the member about the membership and insurance, to provide overviews of compensations, etc.—in other words, to send email communication that is necessary for the correct administrative management of the non‑profit organisation.

Collecting and publishing visual material

During OPENDOEK events, photo and video material are created by our festival photographers. We store these photos in our festival archive, and a selection of the photos and videos is published on our social media channels and in printed materials for subsequent editions.

When publishing recognisable photos in our printed materials, we will make a reasonable effort to obtain permission in advance. If you appear as a subject in one of our photos on Facebook or Instagram and you no longer wish it to be published, please do not hesitate to contact us using the contact details provided in this document.

Do you have questions about OPENDOEK’s privacy policy?

Siebe Nicolai Siebe Nicolai 1

Siebe Nicolai

Communication Coordinator
Hendrik Ramaker Hendrik Ramaker Hover

Hendrik Ramaker

IT, Insurance and Membership Administration
Glen Vandenberghe Glen Vandenberghe Hover

Glen Vandenberghe

Business Management

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