Notification on Processing of Personal Data

The protection of your personal data is important to us.  That is why we would like to inform you about how we use your personal data when you use the websites, applications and social media pages of Vias institute and when you use our services. 

1. Who is responsible for processing your personal data? 

1.1. "Vias institute, Cooperative Society accredited as a Social Enterprise" with registered office at 1130 Brussels, rue Hachtsesteenweg 1405, registered with the Crossroads Bank for Enterprises under number 0432.570.411 (hereinafter "Vias institute", "us" or "we") is the controller of the processing of your personal data via the websites, applications and social media platforms on which Vias institute is present and, in general, when Vias institute processes your data when you make use of our services.

1.2. The DPO ("Data Protection Officer") of Vias institute can be contacted by letter at the aforementioned address or by e-mail at dpo@vias.be.

1.3. For the activities of "Driver improvement", the processing manager vzw Via Secura, with registered office at Haachtsesteenweg 1405, 1130 Brussels, is registered with the Crossroads Bank for Enterprises under number 0673.510.986 ("Via Secura").  

1.4. If you have any questions about our processing of your data, please contact us at the address mentioned in section 1.1 or via dpo@vias.be.

2. For what purposes and on what legal basis are your personal data processed?

2.1. Vias institute processes personal data of visitors to the websites and applications, including the social media platforms on which it is present, for the following purposes: 

  • to answer and follow up the questions and comments that you put to us. This may involve answering (i) questions to obtain brochures and price lists, for example for training sessions, coaching sessions, workshops or framework programmes (ii) questions to obtain an offer, (iii) questions to subscribe to newsletters, and (iv) general questions and comments that you submit to us via our websites, applications and social media pages.  The legal basis for this is the need for the performance of the contract to which you are party, or to take action at your request prior to the conclusion of a contract, as well as our legitimate interest in responding to your questions and comments;
  • to identify you and register with one of our services (CARA, medical and psychological recovery examination, the follow-up of which is required in the event of drink-driving or recidivism, professional support programme described in the Royal Decree of 26 November 2010 relating to the installation of the alcolock and the alcolock reminder programme, training provided by Vias, including in the context of alternative judicial measures, "Driver improvement") to enable Vias institute to provide you with its services, including the analysis of results and the handling of specific procedures for each department;
  • for the administration of your orders and to deliver you the ordered products when you order a product through our webshop;
  • Research, analysis, and improvement of the functioning of websites and applications, improvement of customer service and of our assignments in general; 
  • combating fraud and infringements, and managing disputes and litigation, including, where appropriate, taking action against statements in social media which are denigrating, discriminatory, insulting or in any way contrary to applicable law.  The legal basis for this is our legitimate interest as the person responsible for the website, applications and social media pages on which we operate to detect and curb fraud and infringements, as well as inadmissible or unlawful statements, to secure our IT systems, and to handle disputes;
  • for possible analyses in the context of business restructurings or acquisitions, based on the legitimate interest of Vias Institute and of the parties involved in those transactions to bring those transactions to a successful conclusion;
  • to provide support services to Via Secura; 
  • to comply with legal obligations to which we would be subject.

2.2. If you use the services of Via Secura, Via Secura processes your personal data in order to identify and register you within the "Driver improvement" service and to offer "Driver improvement" services, including the analysis of the results and the handling of the specific procedure within the framework of "Driver improvement".

2.3. In the context of direct marketing (to contact you in order to provide you with information and publicity about Vias institute and Via Secura products and services, and to send you offers that match your interests, such as invitations to events, training courses, coaching sessions, workshops, framework programmes, campaign launches or special offers), we will only use your personal data if you have given your consent (for example, if you have ticked the appropriate box or when placing an order or other contact), except in cases where the regulations do not require such consent. 

3. What categories of personal data do we process?

3.1. Vias institute processes the following categories of personal data for the above purposes:

  • your personal identification details such as your surname and first name, address, e-mail address, telephone (including mobile phone), and personal characteristics (age, gender, date of birth) and language;
  • the name and identification details of your company/organisation and your position therein, as well as your professional contact details, should you communicate them to us when acting on behalf of your company/organisation;

    passwords and logins that you would use to login to certain parts of our websites;

  • preferences relating to the use of the website;

  • IP addresses;

  • data relating to disputes and litigation;

  • data that you fill in via the forms on our websites (e.g. when you place an order via our webshop);

  • other data that you would provide us with spontaneously, for example (i) when you ask us questions via e-mail, or (ii) data that you provide us with when you contact us by telephone using the telephone numbers listed on our website or ask us to call you;

  • information that you spontaneously provide to us when you contact us via social media;

  • data which we would be legally obliged to process.

Only personal data necessary for the purposes in question shall be processed for that purpose.
Providing us with the necessary personal data is voluntary, but it is a necessary condition for us to be able to provide you with an answer to the information you have requested and to follow it up further. 

3.2. In view of the specific activities of the various departments of Vias institute, Vias institute also processes specific data per department when you make use of our services. This concerns, in addition to the data mentioned above:

3.2.1. For Cara:

  • physical characteristics (weight, length, ...);
  • electronic location data (GSM/GPS);
  • details of the professional activities;
  • education and training;
  • electronic identification data (IP address, cookies, ...);
  • family data;
  • criminal proceedings and offences;
  • health data;
  • psychological data;
  • images;
  • information relating to the driving licence;
  • what is called "Model VII" (the certificate of driving ability in the form of Model VII of Annex 6 to the Royal Decree of 23 March 1998 on driving licences);
  • technical data form.

3.2.2.  For medical and psychological recovery examinations:

  • physical characteristics (weight, length,...);
  • Electronic location data (GSM/GPS);
  • details of the professional activities;
  • education and training;
  • electronic identification data (IP address, cookies, ...);
  • family data;
  • Memberships and membership cards;
  • criminal proceedings and offences;
  • consumption patterns;
  • health data;
  • psychological data;
  • hobbies and interests;
  • financial details.

3.2.3 The AR of 26 November 2010 provides for a framework programme for the installation of the alcolock and the framework programme:

  • physical characteristics (weight, length,...);
  • Electronic location data (GSM/GPS);
  • details of the professional activities;
  • education and training;
  • electronic identification data (IP address, cookies, ...);
  • family data;
  • Memberships and membership cards;
  • criminal proceedings and offences;
  • consumption patterns;
  • health data;
  • psychological data;
  • hobbies and interests;
  • data obtained via the notification document ("Avertissement"/"Notification") from the public prosecutor's office (duration of the alcolock, legal basis for imposing the alcolock in the judgment, competent Public Prosecutor);
  • data from periodical and additional downloads of the alcolock. 

3.2.4. For "Driver improvement" (service offered by and under the responsibility of Via Secura):

  • financial data (only for the paid training courses); 
  • electronic location data (GSM/GPS);
  • details of the professional activities;
  • education and training;
  • electronic identification data (IP address, cookies, ...);
  • family data (not for paid training);
  • Memberships and membership cards (not for the paid training);
  • criminal proceedings and offences;
  • health data (not for the paid study programme);
  • psychological data.

3.2.5. For our research department (KCC department):

  • physical characteristics (weight, length,...);
  • Electronic location data (GSM/GPS);
  • details of the professional activities;
  • education and training;
  • electronic identification data (IP address, cookies, ...);
  • family data;
  • Memberships and membership cards;
  • criminal proceedings and offences;
  • minutes of meetings;
  • financial data;
  • sound recordings;
  • health data;
  • psychological data;
  • images - including car accidents and victims.

4. Who has access to your personal data?

4.1. Only employees, employees and the management of Vias Institute have access to your personal data to the extent necessary for the purposes mentioned above.  With regard to "Driver improvement", employees, staff and management of Via Secura have access to your personal data to the extent necessary for the purposes stated above and employees and management of Vias institute have access to your personal data for support services provided by Vias institute to Via Secura. 

4.2. We also use service providers who process your data on our behalf. These may be affiliated companies, but also external service providers such as the service provider hosting the website. The service providers may only use the personal data to the extent necessary for the purposes indicated above.  These service providers have a legal and contractual obligation to take appropriate technical and organisational measures to protect your personal data against loss or unauthorised processing.

4.3. We may also share your personal data with third parties who, in the event of any business reorganisations or takeovers, are involved in those transactions, but only for the purpose of evaluating and carrying out those transactions.  In general, we may also share your personal data with advisers and lawyers in the context of advice, disputes and litigation.

4.4. We will not pass on your details to other third parties without your permission, unless we are legally obliged to do so or on the basis of a judicial or administrative order or instruction from a competent government or institution.

4.5. Our websites, applications and pages on social media may contain links or references to other sites for your information or convenience.  We are not responsible for the content of these sites or for the processing of your personal data by these sites, including by the social media platforms on which we operate.  We would like to refer you to the privacy policies of the sites and social media platforms concerned.

5. Is your data transferred outside the EU?

In principle, your personal data will not be transferred outside the EU. 
However, should your data be transferred outside the EU for a specific service, you will be informed when you register for that service and you will be informed whether or not the Commission has adopted an adequacy decision declaring the level of protection of the third country in question to be adequate and, where applicable, the appropriate safeguards to implement that transfer. 

6. How long will your personal data be stored?

Vias institute and Via Secura retain your personal data for as long as necessary for the purposes stated in this policy. 
This means that this data is kept (i) to answer and follow up the questions you ask us via our website: up to 12 months after your request has been processed or, if a commercial relationship arises from this, for as long as that relationship continues, (ii) when you register to receive newsletters, for as long as you no longer wish to do so, (iii) to combat fraud and infringements and to pursue disputes: for as long as the dispute continues, (iv) for use in business reorganisations and takeovers: as long as our contractual relationship continues, (v) for direct marketing: as long as indicated in information provided to you when you give your consent, (vi) for orders via the web shop: the time needed to deliver the product to you and to follow up the order and (vii) for compliance with other legal provisions: as long as required by law.  We will remove your personal data in any case 5 years after our last contact, unless we have to keep them longer due to a legal obligation or due to an ongoing or potential dispute.

7. Do we use automated decision-making? 

Article 22 of the GDPR provides that individuals have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning them or otherwise significantly affects them.
Vias institute and Via Secura make no use of such automated decision making. 

8. What measures do we take to ensure safe processing? 

8.1. Vias institute and Via Secura take the appropriate and reasonable technical and organisational measures to ensure, in the light of the possible risks, an appropriate level of security for the preservation of the integrity, confidentiality and availability of your personal data.  These measures include (i) the retention of personal data in secure operational environments that are not accessible to the public and to which only authorized employees, employees, management, representatives and subcontractors of Vias Institute and Via Secura have access; and (ii) the verification of the identity of registered users of our websites before they gain access to their personal data.

8.2. The third party service providers we use also have a legal and contractual obligation to take appropriate technical and organisational measures to protect personal data against loss or unauthorized processing.

9. What are your rights under the GDPR? 

In accordance with the GDPR, you have:

  • the right to request us to inspect, rectify or delete any personal data we process about you;
  • the right to ask us to restrict the processing that concerns you, as well as the right to object to the processing;
  • the right to request us to obtain the personal data you have provided to us in a structured, common and machine-readable form in order to transfer them to another data controller (so-called "data transfer right");
  • the right to withdraw consent at any time with respect to processing operations that would be based on your consent, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to withdrawal;
  • the right to complain to the supervisory authority.

Some of these rights can only be exercised within the conditions and limits set by the GDPR.  In any case, you have the absolute right to oppose the further use of your personal data for direct marketing purposes.

Our contact details for the exercise of your rights are set out in point 1 of this notice.  If you exercise your rights, we may ask you to provide us with additional information to help us verify your identity and find your details.

10. What are cookies and what cookies do we use?

The Website uses "cookies".
A cookie is a small data file sent from a web server to your browser and stored on your device's hard drive.  Cookies enable us to recognize you as a (representative of a) User when you later visit our site with the same device and internet browser.  The main purpose of cookies is to increase your ease of use.  Cookies save you time and adapt our site to your interests and needs. A cookie is also intended to let the web server know that you have returned to a specific page. Cookies can also be used to make your future visit to and use of our site smoother.  To further improve the use of our site, we may allow authorized third parties to send cookies to your browser.  We only store encrypted personal data in our cookies so that actual identification is reasonably impossible.
You can accept or refuse cookies.  Most Internet browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.  If you decide to decline cookies, you may not be able to use all or part of our site. For more information on how to change or modify your browser settings, please refer to the user instructions or help function of your internet browser.  Below you will find information on how to block cookies for different browsers:

We use the following cookies:

Necessary cookies: these are necessary to use the Website and provide a secure identity check. They are the following cookies:

  • User-token: This cookie assigns a unique ID to each user who logs in via a general login.
  • Download: This cookie keeps track of the files a user adds to his/her download basket.

Functional cookies: these ensure the smooth functioning of our site and provide a personalized browsing experience, for example by remembering passwords and certain preferences, such as the language setting. These are the following cookies:

  • language: This cookie remembers a user's choice of language.
  • allow_cookies: This cookie remembers whether a user has accepted the cookie banner.
  • PHPSESSID: This cookie is used to identify the PHP session, which means that additional functionalities can be provided on the website.

Analytical cookies: these are cookies that allow us to analyse our site, for example to determine how many visitors visit the Website and for how long, what they have clicked on or which parts of the Website are visited the most.   In this way, we can always improve the functioning of our site for you.  It concerns the following cookies:
Cookie Google analytics:

  • _ga: This cookie stores data about the use of the site (which pages are visited, time spent on site/page, origin of the visitor, ...).
  • _gid: This cookie stores data about the use of the site (which pages are visited, time spent on site/page, origin of the visitor, ...).

Social media and external cookies: if you are logged in to your social media websites (Facebook, Twitter, YouTube, etc.) and give permission for this category of cookies on our site, you can use additional functionalities. For example, you can easily share information via Facebook Like, Twitter, etc. For the cookies that the social media parties place and the possible data that they collect, we refer to the statements that these parties provide on their own websites. Please note that these statements may change regularly. Vias has no influence on this.

Cookie settings

Below you can indicate which types of cookies Vias Institute is allowed to keep track of:

      These cookies are required for the website to work and cannot be disabled.
      These cookies increase the user-friendliness of a website by remembering your choices (e.g. language preferences, region, login).
      These cookies collect data about the performance of a website such as the number of visitors or the time visitors spend on a web page.

      These cookies can be set by advertisers on our website. They may be used by those companies to profile your interests and show you relevant ads on this website or other websites. They do not directly store personal information, but they are based on unique identifiers of your browser and Internet device. If you do not allow these cookies, you will see fewer ads targeted at you.

      11. Modifications

      Vias institute and Via Secura reserve the right to make amendments to this privacy policy if required in the light of legislative changes or guidelines from the competent supervisory authority, as well as if our data processing processes change.  Changes will always be communicated via our website www.vias.be. We therefore advise you to visit our website regularly in order to keep abreast of any changes.

      Last update: 17/07/2020