PRIVACY POLICY

 

Please carefully read this Privacy Policy before you access and use this Platform and our Services.

1. Overview

This Privacy Policy describes the privacy practices of Microfact.Org in connection with this Platform and its Services and the rights available to our Users with respect to their Personal Information.

Microfact.Org understands that privacy is important to our Users. We are committed to protecting the privacy of your Personal Information as you use our Platform and Services.

Microfact.Org main offices are located in Belgium and Luxembourg, therefore we guarantee that your Personal Information is protected by all privacy and data protection rights applicable under the laws of Belgium and Luxembourg as well as other countries, just as by all international privacy and data protection treaties, and the General Data Protection Regulation (GDPR) approved by the European Parliament.

This Privacy Policy tells you how we protect and use the information we gather from you.

2. General Provisions

This Privacy Policy constitutes a legally binding agreement between you and Microfact.Org.  

The Microfact.Org Platform (“Platform”) and its Services are offered subject to your acceptance of this Privacy Policy.

For the purposes of this document, “Microfact.Org” and/or “We” and/or “Us means collectively this Platform, including the Website: https://microfact.org, jointly owned and operated by Appui au Développement Autonome (ADA) and the Belgian Raiffeisen Foundation (BRS). “You” and/or “User” means any individual or entity who may access, browse and/or use our Platform and its Services.

You should also read our Terms of Use to understand the general rules about your use of our Platform and its Services.

This Privacy Policy is incorporated into and subject to our Terms of Use. The definitions set out in those Terms of Use, as defined in Section 32 shall apply to this Privacy Policy.

By accessing, browsing and/or using any of our Services on this Platform, you are expressly accepting and electronically providing your consent to all the provisions of this Privacy Policy on your own name and on behalf of any entity or individual represented by you for such purposes. If you do not agree with this Privacy Policy, you must not use our Services and leave this Platform immediately.

3. When Does Our Privacy Policy Apply

This Privacy Policy applies to any information collected from you (“Personal Information”) in accordance with this document, when you access and use our Platform and Services.

This Privacy Policy also applies to any Personal Information collected from you when you contact us by email or on other occasions.

4. When Does Our Privacy Policy Not Apply

This Privacy Policy does not apply to any information about you that you have provided to third parties and/or publicly available with no restrictions. We are not responsible for the privacy practices of third parties.

5. Data Controller and Data Processor

We are the Data Controller and Data Processor of your Personal Information. Our details are as follows:

• Business Name: Microfact.Org.
• Owners: Appui au Développement Autonome (ADA); and The Belgian Raiffeisen Foundation (BRS)
• Address: Muntstraat 1, 3000 Leuven, Belgium / 39 rue Glesener, L-1631 Luxembourg.
• Emails: microfact@brs.coop / rgpd@ada-microfinance.lu
• Phone Numbers: +070 69 52 42 (Belgium) / +352 45 68 68 1 (Luxembourg).
• Fax Number: +352 45 68 68 68 (Luxembourg).

6. Your Consent

By accepting this Privacy Policy you expressly agree to grant Microfact.Org a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, sub licensable right, to exercise the copyright, publicity, and/or any database rights (but no other rights) you have on your Personal Information, in any media now known or that may be known in the future with respect to your Personal Information, solely for the purpose of enabling us the use of the information you provide to us for the use of our Platform and our Services and to avoid the violation of any rights over that information.

You have the right to withdraw your consent at any time, in which case you must  leave our Platform immediately and suspend the use of our Services. If you withdraw your consent, our Terms of Use and this Privacy Policy will terminate immediately.

By accepting this Privacy Policy, you expressly agree that Microfact.Org is the Data Controller and Data Processor of your Personal Information.

7. Information Collected By Us

The Personal Information collected by us will solely be used in reference to the Services provided by Microfact.Org through its Platform.

In this Privacy Policy, every time we mention “Personal Information” and/or “Information”, we will be referring to any information about you that we collect when you use our Platform and Services.

By accepting this Privacy Policy, you grant us your consent to collect and use your Personal Information in accordance with this Privacy Policy and our Terms of Use.

We reserve the right to confirm and validate your Personal Information and any other information provided by you at any time. In the event that we determine that the information provided by you is unlawful, fraudulent, erroneous or incorrect (totally or partially), we may cancel your access and use of our Platform and Services, including our Workshops, at any time, and without prior notice.

We have the right to file a proceeding if you provide unlawful, fraudulent, erroneous or incorrect information, in addition to using any other legal remedy available according to applicable legislation.

The Personal Information we collect from you is as detailed below:

1. Information provided by you during checkout process:

• First and last name;
• Street and house number;
• City;
• Zip code;
• Country;
• Email address;
• Phone number.
• Payment Method.

If you are a company, you will also need to provide us the following information:

• Company name;
• Company ID;
• VAT Reg N°.

  2. Information provided by you when you download our Tools:

• Title (Mr./Mrs);
• First and Last Name;
• Email;
• Organisation;
• Type of Organisation;
• Country (optional);
• Website (optional);
• Phone number (optional).

  3. Information provided by you when you contact us through the contact form available on our Website:

• Name and Last Name;
• Email;

  4. Information automatically collected by us:

• Device data, such as Device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before accessing and using our Platform and our Services.
• Online activity data, such as pages or screens you viewed on our Platform through our Website how long you spent on a page or screen; navigation paths between pages or screens; information about your activity on a page or screen, access times, and access duration.

8. Information Restrictions

Your Personal Information shall not: (a) be inaccurate, incorrect or misleading; (b) be fraudulent; (c) infringe any third party’s copyright, patent, trademark, trade secret or other proprietary rights or rights to publicity or privacy; (d) violate any applicable national or international law, statute, ordinance or regulation; (e) be unlawfully, prohibited, abusive or in any way objectionable; (f) contain any viruses, trojan horses, worms, time bombs or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or Personal Information.

9. Data Retention Period

We may retain and store your Personal Information until necessary but for a limited period of time that may not exceed 1 year, since the last purchase made through our Platform.

Please keep in mind that in some circumstances, we may retain your Personal Information for longer periods but in an anonymized form. This means we would delete any information which identifies you personally. We may also retain your Personal Information where such retention is necessary for compliance with a legal or regulatory obligation to which we may be subject to.

10. Data Subject Rights

Your rights on your Personal Information are the following:

Right to Access and Data Portability. You may issue queries or ask questions about your Personal Information by email at any time, and we will provide you with such information in a structured, commonly used, machine-readable format, or (where technically feasible) to have it ported directly to another data controller, provided this does not adversely affect the rights and freedoms of others.

Right to Data Rectification. You have the right to ask us to update and/or rectify and/or complete your inaccurate or incomplete Personal Information. Please note that notwithstanding that all reasonable efforts will be made by us to keep your Personal Information updated, you are kindly requested to inform us promptly of any change, error or inaccuracy in your Personal Information.

Right to Data Objection or Restriction. You have the right to object or request us to suspend the processing of your Personal Information when you have a legitimate interest (or those of a third party) and there is something about your particular situation that causes you to object to the processing of such Information because it makes you feel it impacts your fundamental rights and freedoms. Please note that we only process your Personal Information when this is necessary to provide you with our Services and/or when it is necessary to comply with a legal obligation to which we are subject to, as when processing is necessary to protect your interests or those of another person or entity. 

Right to Data Deletion. You have the right to ask us to delete your Personal Information when it is not relevant to the purpose for which we collect it, once the period established in Section 9 above has elapsed. We may delete your Personal Information before the expiration of that period, when such information is not necessary, at our sole discretion.

However, please note, there may be legal obligations which may prohibit us from deleting all or part of the Personal Information held about you immediately at the time of the request, however, we will process your request at the earliest opportunity whenever the information retention period expires in accordance with Section 9 above.

11. How To Exercise Your Rights

You may exercise the rights described in Section 10 above, at any time, by contacting us at microfact@brs.coop or rgpd@ada-microfinance.lu, or by contacting the competent regulatory authority of your Country.

All communications with us must be through the email address that you have provided to us during the checkout process. Please note that we will verify your identity prior to responding to any request.

We try to respond to all legitimate requests within 5 business days. Please keep in mind that occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated on the status.

12. Use Of Your Information

We use your Personal Information for the following purposes:

• Providing, operating and improving our Platform and its Services.
• To process billing and checkout any Workshop(s) purchased by you.
• Sending your order details and payment instructions.
• Sending you the access code to enable you to participate in the Workshop(s) purchased.
• To enable security features on our Platform; contact you about our Services, including sending you announcements, updates, security alerts, and support and administrative messages.
• Sending you marketing communications and newsletters related to our Services as permitted by law.
• For research and development purposes, including analyzing and improving our Platform and its Services.
• In order to comply with applicable laws and regulations.

13. Information Disclosure

You expressly agree that we may share and/or disclose your Personal Information in accordance with applicable laws. We should cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights and other rights, to help protect you and all our Users from any crime or fraud. For this reason, and in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal or fraudulent activity, we may (and you expressly authorize us to) disclose your Personal Information, user history, billing information, purchases records, fraud complaints, and similar information without a subpoena. However, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm, fraud or financial loss; or report suspected illegal or fraudulent activities.

14. Data Protection

We guarantee the privacy and confidentiality of your Personal Information and also guarantee that we have implemented physical and electronic security measures, as well as other appropriate administrative procedures to prevent unauthorized or illegal access by third parties to your Personal Information.

Our privacy practices include, but are not limited to:

1. The continuous review and updates of our security policies and controls, as technology changes to ensure ongoing information security.

2. Implementation of reasonable and appropriate technical and organizational security measures to protect the Personal Information we process, from unauthorized access, alteration, disclosure, loss or destruction.

3. Regular audits of the security measures of our Platform by requesting third party experts to review our security controls against international standards. These audits help us to further improve our security levels.

4. All information is encrypted in transit, and where possible specific fields are encrypted at rest using industry recognized cryptographic measures.

15. Information Shared With Third Parties

We do not use, share, sell and/or exchange any of your Personal Information with third parties for any purposes without your express consent.

Please note that in order to enable you access to our Platform and allow you the use of our Services, we may share your Personal Information with our partners and/or companies, through the following sub-domain:  https://microfact.lmsdokeos.com/ and/or with the providers we hire so we may perform our Services or which operate on our behalf  (“Data Processors”) as our service providers. In all cases in which we share your Personal Information with a third party for the purpose of providing you our Services, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

By accepting this Privacy Policy, you expressly give us authorization to use and share your Personal Information with our Data Processors, under their corresponding privacy conditions, within the limits set in this document.

We are not responsible for the privacy practices of our partners and/or service providers and/or any third party.

16. International Data Transfers

We are domiciled in Belgium and Luxembourg and provide our Services globally. We process and store your information in Belgium and/or Luxembourg, however, our partners and/or service providers (“Data Processors”) may process and store it in such countries and/or any other place.

If you are located outside Belgium or Luxembourg and choose to provide us with your Personal Information, we will transfer such information to Belgium and/or Luxembourg for due processing, and our Data Processors may process your Personal Information in our countries and/or any place else. You expressly accept and acknowledge that such countries may not have the same data protection laws as your country or the country in which you initially provided your Personal Information. Notwithstanding, we will ensure that our Data Processors apply at least the basic data security standards so that your Personal Information remains undisclosed and secure.

By accepting this Privacy Policy, you have expressly given us authorization to transfer your Personal Information to our servers located in Belgium and/or Luxembourg and/or to the servers held by our Data Processors located in their relevant countries, if necessary, to provide you with our Services.

For clarification purposes, data transfers will be subject to the information detailed below:

• Data Controller: Org.

• Data Processors: Org and/or our partners and/or service providers.

• Place: Belgium or Luxembourg.

• Category of Data Subjects: Individuals and organisations working in, or related to the microfinance and microinsurance sector interested in receiving  financial tools, workshops and training courses.

• Data Category: Personal Data referred in Section 7 above.

• Nature of the Processing: Collection, process and storage.

17. Cookies

We also may use a standard feature found in browser software called “Cookie” to enhance your experience with our Platform and its Services. Cookies are small files that your web browser places on your device for record-keeping purposes. By showing how and when you use the Platform, cookies help us identify how many Users visit us, and track User trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Platform where you may have entered preference information before.

Please note that our partners or some advertisers may also collect information from you on our Platform by using Cookies. They may use the information they collect to help present their advertisements, to help measure and research the advertisements’ effectiveness, or for other purposes. The use and collection of your information by these third parties is governed by their privacy policies and is not covered by this Privacy Policy. If you have any concerns about a third party’s use of Cookies or use of your information, you should visit that website of such third-party and review its privacy policy.

By accessing and using our Platform and Services, you expressly agree that we may use Cookies for the purposes described herein. If you do not agree with our use of Cookies, please do not access or use our Platform and Services.

To restrict or block any Cookies used on this Platform, you will only need to change the browser settings in your device to access our Platform. Please be aware that some of our Services will not operate if your browser does not accept our Cookies. For more details about how to restrict or block Cookies, please visit: http://www.allaboutcookies.org.

18. Nous contacter

For any questions, comments, or complaints regarding this Privacy Policy, you may address us by sending an email to info@microfact.org or rgpd@ada-microfinance.lu . You may also contact us through our Platform, in the About Us of our Website, using the contact form available there.

Last Updated: 04/11/21 .