This translation is provided for information only. In case of discrepancy, the French version prevails.
1. Introduction
Airplan SRL (hereinafter "Airplan") is committed to protecting your personal data and to processing it in accordance with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679 of 27 April 2016) and with applicable Belgian legislation.
This privacy policy applies to all pages hosted on https://bruxelles.airplan.be and to the forms offered on this site. We recommend that you consult it regularly, as it may change. Any amendment will take effect on the date of publication and will never be retroactive, unless otherwise required by law.
2. Data controller and Data Protection Officer
Data controller: Airplan SRL, Rue des Houblonnières 53, 4020 Liège, bonjour@airplan.be, 0460 94 98 97
Data Protection Officer (DPO): An internal DPO has been appointed within Airplan SRL. For any question relating to your personal data, you can contact the DPO at: bonjour@airplan.be
3. Personal data collected
We collect the following categories of data:
- E-mail address and, optionally, first name and sign-up source, when you join the waiting list via Brevo
- E-mail address, description of the problem and, optionally, additional contact details when you leave negative feedback on an article
- Pseudonymised browsing data (pages viewed and interactions with calls to action) via PostHog
We do not collect any so-called "sensitive" data within the meaning of the GDPR (health, political opinions, religion, etc.).
4. Legal bases for processing
In accordance with Article 6 of the GDPR, each processing operation is based on a specific legal basis:
| Purpose | Legal basis | Details |
|---|---|---|
| Joining the waiting list | Consent (Art. 6.1.a) | The user gives express consent when submitting the form |
| Feedback on an article | Consent (Art. 6.1.a) | Voluntary submission of the feedback form |
| Cookieless audience measurement | Legitimate interest (Art. 6.1.f) | Improving the guide using pseudonymised data stored in memory only |
5. Data retention period
- Waiting list data: kept in Brevo until you unsubscribe or request deletion
- Feedback on articles: forwarded to Airplan's Slack workspace for internal handling
- Browsing data: kept in accordance with the retention settings applied by Airplan in PostHog
Beyond these periods, your data is deleted or irreversibly anonymised.
6. Processors and data transfers outside the EU
6.1 Processors
Airplan uses the following processors, with whom data processing agreements (DPAs) have been or are to be concluded:
- Cloudflare: hosting and delivery of the static site
- PostHog: cookieless audience measurement with in-memory persistence only
- Brevo (formerly Sendinblue): management of the waiting list
- Slack: internal receipt of sign-up notifications and feedback on articles
6.2 Transfers outside the European Union
Some service providers may process data outside the European Union. These transfers are governed by the mechanisms provided for by the GDPR, in particular adequacy decisions or the Standard Contractual Clauses adopted by the European Commission.
The service providers concerned and the data transferred are as follows:
- Cloudflare: technical data needed for the security and delivery of the site
- PostHog: pseudonymised browsing events
- Slack: content of feedback on articles and internal notifications
Brevo offers data hosting within the European Union.
Airplan does not transfer your personal data to third parties for commercial purposes without your explicit consent.
7. Use of cookies
This site does not use analytics or marketing cookies. PostHog is configured without cookies, with persistence limited to the browser's memory. The forms and content remain readable and usable without this audience measurement.
8. Web beacons
The site does not use its own web beacons. However, any e-mails sent via Brevo may contain tracking mechanisms managed by that provider, depending on the campaign configuration.
9. Data security
Airplan implements appropriate technical and organisational measures to protect your data against loss, unauthorised access, disclosure, alteration or destruction, in accordance with Article 32 of the GDPR.
However, no transmission of data over the Internet can be 100% guaranteed. In the event of a data breach likely to result in a risk to your rights and freedoms, Airplan will notify the APD (Belgian Data Protection Authority) within 72 hours and will inform you if the risk is high.
10. Your rights
Under the GDPR (Articles 15 to 22), you have the following rights regarding your personal data:
- Right of access: obtain a copy of the data we hold about you
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure ("right to be forgotten"): request the deletion of your data in certain cases
- Right to restriction of processing: restrict the use of your data in certain cases
- Right to data portability: receive your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interest
- Right to withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal
To exercise these rights, contact us at: bonjour@airplan.be or by post at Airplan SRL, Rue des Houblonnières 53, 4020 Liège. We will reply within a maximum of 30 days.
You also have the right to lodge a complaint with the Belgian Data Protection Authority (APD):
- Website: www.autoriteprotectiondonnees.be
- Telephone: +32 2 274 48 00
- Address: Rue de la Presse 35, 1000 Bruxelles
11. Changes to this policy
Airplan reserves the right to amend this policy. In the event of significant changes affecting your rights, we will inform you by e-mail or through a clearly visible notice on our site before the changes take effect. No change will apply retroactively.
12. Contact
- E-mail: bonjour@airplan.be
- Telephone: 0460 94 98 97
- Postal address: Airplan SRL, Rue des Houblonnières 53, 4020 Liège