Liberi Ludi AISBL takes the protection of your personal data seriously. This Policy explains, in general terms, what data we collect on liberiludi.com, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have. It also covers our use of cookies.
This Policy is governed by the General Data Protection Regulation (Regulation (EU) 2016/679, "RGPD" / "GDPR") and the Belgian Data Protection Act of 30 July 2018. The French-language version is the authoritative version in case of dispute.
Liberi Ludi AISBL Chaussée d'Ixelles 240, 1050 Ixelles, Belgium BCE 1035455303 Contact for privacy questions:
liberi@liberiludi.com
Liberi Ludi has not appointed a Data Protection Officer (DPO), as the scale and nature of our processing do not require one under Art. 37 RGPD. The Board acts as the point of contact for data protection matters.
We collect only what we need to operate Liberi Ludi's activities.
Creative Space participant data — name, professional name, contact details (email, optional phone), professional information (bio, role, areas of practice, languages, country of activity, optional self-declared migration experience), and samples of work submitted as files or links. We process this on the basis of your consent (Art. 6(1)(a) RGPD), in order to publish your profile and match you to opportunities.
Project submissions ("Share your project") — name, organisation, contact details, project description, supporting files. Lawful basis: consent. Purpose: assessing fit with our programmes and replying.
Newsletter subscription — email, optional name, optional preferences (languages, role). Lawful basis: consent. Purpose: sending the newsletter.
Donor data (in future, once banking is in place) — name, address (where required by Belgian tax law), donation amount and method, contact details. Lawful basis: legal obligation (Art. 6(1)(c)) for accounting records; consent for communications. Card and bank data are processed by our payment processor; Liberi Ludi never sees or stores full card numbers.
Contact emails — when you write to us, we receive your email address and the content of your message. Lawful basis: consent and legitimate interest.
Technical data — IP address, browser type, pages visited, referring page. Lawful basis: legitimate interest (Art. 6(1)(f)), for security and basic traffic understanding. We do not profile users or serve advertising.
Liberi Ludi works with the topic of migration. A participant may, voluntarily, indicate that they themselves have lived experience of migration. This is processed only on the basis of explicit consent and only to the extent the participant chooses to make it part of their public profile.
We do not knowingly collect personal data of children under 16 through the Site. The Site is not directed at children. All forms are intended for adults (artists, educators, donors, partner-organisation representatives).
We share data only with the following categories of recipients:
• Processors acting on our behalf — the following named providers process personal data on our written instructions, under Data Processing Agreements as required by Art. 28 RGPD, and may not use your data for their own purposes:
- Hostinger (UAB "Hostinger International", Lithuania, EU) — web hosting of liberiludi.com. The site itself runs on WordPress.
- Brevo (Sendinblue SAS, France, EU) — newsletter delivery and form submissions (Creative Space, Share your project, Subscribe, Contact). Brevo stores your form-submitted data and your newsletter subscription on EU servers.
- Payment processor — to be named on the page /donate once banking arrangements are in place.
- Partner organisations — where you have submitted a profile or project and we propose you to a third-party partner for a specific opportunity, we share the information necessary to make the proposal. You consent to this when you submit the form (see Terms and Conditions, section 2.4). You can withdraw this consent at any time.
• Public authorities — where we are required to share data by Belgian law (tax authorities, regulators, courts).
We do not sell or rent personal data. We do not share data with advertising networks. As both Hostinger and Brevo store data within the European Union, no personal data is transferred outside the European Economic Area in the normal operation of the Site.
Data
Retention period
Active Creative Space profile
For the duration of participation; 12 months after removal unless earlier deletion is requested
Project submissions
Not taken up 24 months, then deleted
Project submissions leading to collaboration
10 years after the end of the collaboration (legal and accounting purposes)
Newsletter subscription
Until you unsubscribe; inactive emails deleted after 24 months
Donor records
10 years (Belgian accounting law)
Contact emails
24 months, unless part of an active file
Site technical logs
12 months
Where the law requires a shorter or longer period, the law prevails.
Under the RGPD you have the rights of: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21), and withdrawal of consent at any time (Art. 7(3), without affecting the lawfulness of past processing).
You also have the right to lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données — APD), Rue de la Presse 35, 1000 Brussels, autoriteprotectiondonnees.be.
To exercise any of these rights, write to
liberi@liberiludi.com
. We may ask you to verify your identity before we process the request. We will respond within one month (extendable by two months for complex requests).
We apply reasonable technical and organisational measures to protect personal data: HTTPS in transmission, access controls on form-submission storage, training of the Board on data handling, contractual safeguards with all processors. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the APD within 72 hours and, where applicable, affected individuals.
A cookie is a small text file that a website places on your device. Cookies allow the site to remember information about your visit. This Policy and the cookie banner on the Site explain what cookies we use.
The Site uses only technical (essential) cookies that are necessary for the Site to work — for example, to remember that you have closed the cookie notice itself, or to keep a form working across pages. These cookies do not track you, do not identify you personally, and do not require your prior consent under the ePrivacy framework.
We do not currently use analytics cookies, advertising cookies, or social media tracking pixels.
If Liberi Ludi later adds analytics (such as a self-hosted Plausible or Matomo, or Google Analytics), or embeds content that sets cookies (YouTube videos in standard mode, Instagram posts, Mailchimp embedded forms), this Policy will be updated and the cookie banner will switch to a consent banner with the standard buttons "Accept all", "Reject all", and "Customise". No non-essential cookies will be set before your explicit consent.
Where possible we will use privacy-respecting alternatives: YouTube embeds in youtube-nocookie.com mode, Matomo or Plausible (cookie-free) rather than Google Analytics, native HTML forms rather than third-party embeds.
You can also manage or delete cookies through your browser settings (Chrome, Firefox, Safari, Edge). Disabling essential cookies may break parts of the Site.
We may update this Policy. The version in force is always the one published on this page, dated at the top. Material changes will be announced in the Liberi Ludi newsletter and, where appropriate, by direct email.
For any privacy or cookies question:
Liberi Ludi AISBL Chaussée d'Ixelles 240, 1050 Ixelles, Belgium
liberi@liberiludi.com